T.C. Memo. 1997-412
UNITED STATES TAX COURT
DARRELL D. AND JANE E. MORAN, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 5374-96. Filed September 17, 1997.
Darrell D. and Jane E. Moran, pro sese.
James Gehres, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
GERBER, Judge: Respondent, by means of a notice mailed
February 16, 1996, determined an $11,701 income tax deficiency
for petitioners’ 1994 taxable year. The sole issue for our
consideration is whether the amount of $37,840 received by
Darrell D. Moran1 (petitioner) as the result of the termination
1 Jane E. Moran is a petitioner solely because she filed a
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